Petition for Writ of Certiorari — Onyinye Jideani, Petitioner v. Hilton Worldwide Holdings, Inc.

2=781® ORIGINAL

FILED

JUN 1 5 2023

IN THE

SUPREME COURT OF THE UNITED STATES

Onvinve Jideani pro se _ petitioner

(Your Name)

Hilton Worldwide Holding^ Inc.,

(formerly Hilton Hotel Corporation)

— RESPONDENT(S)

ON PETITION FOR A WRIT OF CERTIORARI TO

The District of Columbia Court of Appeals (DCCA)

(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)

PETITION FOR WRIT OF CERTIORARI

Onyinye Jideani

(Your Name)

2121 First Street SW, Apt. 618

(Address)

Washington DC, 20024-3589, U.S.A.

(City, State, Zip Code)

202-704-1486

(Phone Number)

pg. 1 of X®

QUESTION(S) PRESENTED

1. Did the District of Columbia Court of Appeals (DCCA), violate exiting laws

guaranteed by the U.S. Constitution, and breached its duty to protect and

preserve the substantive right of pro se litigant “petitioner Onyinye Jideani,"

when granting the respondent "Hilton Worldwide Holdings Inc.’s

(formerly Hilton Hotel Corporation) renewed Motion for Summary Affirmance “and

on the lower court's October 21, 2022 unlawful and unjudicial dismissal of

petitioner's May 09, 2022 Unlawful Discriminatory Practice claim civil action suit

against the respondent, "for Want of Prosecution" (of which this petition for Wr of

Certiorari is taken),” if in-fact petitioner Onyinye Jid

and pursued

her civil action suit with “procedural, sufficient, and timely” filings, in the lower

court “(the District of Columbia Superior Court civil action division),” and as shown

issued

in the courts docket case No. 2022 CA 002012 B? (Dismi

on October 25, 2022).

Want of Prosecution is defined in the Black Law dictionary, as "failure of a litigant

to pursue the case." (See DCCA Appeal case No. 22-CV-866)

A. Did the District of Columbia Court of Appeals, erred when disregarding the

lower court's failed cognizance and abuse of process, on petitioner Onyinye

Jideani's May 09, 2022 substantially justificed Unlawful Discriminatory

Practice claim suit aganistthe respondent Hilton Worldwide Hold

Inc.

(formerly Hilton Hotel Corporation), and when the District of Columbia

Superior Court civ. act. divison "under judge Robert R. Rigsby" dismissed

the May 09, 2022 suit for Want of Prosecution during the first and only

hearing held via WebEx webcam on October 21, 2022? (The lower court’s

dismissal order was issued on October 25, 2022).

All supporting evidences were submitted to the D.C. Appeals

court (DCCA) "Appeal case No. 22-CV-866," appealing the lower court’s

unjust, unjudicial, and erroneous decision.

B. Did the District of Columbia Court of Appeals, fail to redress the lower

court's unjust error, and when the "District of Columbia Superior Court

civ. action division" unlawfully dismissed the petitioner Onyinye Jideani’s

May 09, 2022 Unlawful Discriminatory Practice claim suit for Wa of

Prosecution, fasely alleging that because petitioner Onyinye Jideani did not

attend the initial conference hearing "(referred to as a status hear

"and

for good cause shown," petitioner Onyinye Jideani did not plead her case?

(The lower court's dismissal order was issued on October 25, 2022).

All supporting evidence were submitted to the D.C. Appeals court

(DCCA) "Appeal case No. 22-CV-866," appealing the lower court's

unjust, unjudicial, and

LIST OF PARTIES

(X] All parties appear in the caption of the case on the cover page.

[ 3 Ail parties do not appear in the caption of the case on the cover page. A list of

all parties to the proceeding in the court whose judgment is the subject of this

petition is as follows:

RELATED CASES

TABLE OF CONTENTS

OPINIONS BELOW.

1

JURISDICTION

.2

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

3

STATEMENT OF THE CASE

.4

REASONS FOR GRANTING THE WRIT

.5

CONCLUSION

6

INDEX TO APPENDICES

APPENDIX A: The District of Columbia Court of Appeal’s March 21, 2023

Judgment granting the respondent "Hilton Worldwide Holdings Inc.’s

(formerly Hilton Hotel Corp)” renewed motion for Summary Affirmance, and

dismissing the appeal case No. 22-CV-866.

APPENDIX B: Petitioner Onyinye Jideani's March 22, 2023 petition for

rehearing DCCA Appeal case No. 22-CV-866.

APPENDIX C: The District of Columbia Court of Appeal’s April 03, 2023 Order

denying petitioner Onyinye Jideani's March 22, 2023 petition for rehearing

DCCA Appeal case No. 22-CV-866.

APPENDIX D: Petitioner Onyinye Jideani’s November 08, 2022 Notice to

Appeal D.C. Superior Court civil action case No. 2022 CA 002012 B

“Onyinye Jideani vs. Hilton Worldwide Holdings Inc.,” in D.C. Court of

Appeals (DCCA) case No. 22-CV-866 "(of which this petition for Writs of

Certiorari is taken)”

APPENDIX E: Petitioner Onyinye Jideani’s December 28, 2022 “Designation

of parts of the records Appellant Onyinye Jideani intends to include in the

Appendix, and a Statement of the issues the Appellant intends to present for

review,” in DCCA Appeal case No. 22-CV-866.

p3-

APPENDIX F: Respondent Hilton Worldwide Holdings Inc/s (formerly Hilton

Hotel Corporation) December 20, 2022 Motion for Summary Affirmance

(F1) "renewed on February 28, 2023 (F2)," in DCCA Appeal case No. 22CV-866; as Appendix FI and Appendix F2

APPENDIX G: The District of Columbia Court of Appeal’s January 05, 2023

Order denying without prejudice Appellee Hilton’s December 20, 2022

Motion for Summary Affirmance, and directing Appellant Onyinye Jideani

to file her Brief and Appendix, in DCCA Appeals case No. 22-CV-866.

APPENDIX H: Petitioner Onyinye Jideani's February 11, 2023 “50-page” Brief

"with Appendix,” in DCCA Appeal case No. 22-CV-866; Processed and

filed in the D.C. Court of Appeal’s court docket by the Clerk on

February 13, 2023 “as redacted.” (Only the Brief is submitted with this

petition for Writs of Certiorari).

APPENDIX I: The District of Columbia Court of Appeal’s (DCCA), November

08,

2022

Appeal

case

No.

22-CV-866

court

docket view,

“captioned Onyinye Jideani vs. Hilton Worldwide Holdings Inc.”

APPENDIX J: The District of Columbia Superior Court “(lower court)" civil

action case No. 2022 CA 002012 B’s August 23, 2022 Order sua sponte

rescheduling the initial conference/scheduling hearing, to review pending

motions filed by plaintiff Onyinye Jideani.

APPENDIX K: The District of Columbia Superior Court “(lower court)” civil

action case No. 2022 CA 002012 B’s October 25, 2022 “Order Under Rule

41(b)," dismissing civil action case No. 2022 CA 002012 B "captioned

Onyinye Jideani vs. Hilton Worldwide Holdings Inc.,” without prejudice for

Want of Prosecution, during the rescheduled October 21, 2022 initial

conference/scheduling.

APPENDIX L: The District of Columbia Superior Court “(lower court)” civil

action case No. 2022 CA 002012 B "court docket view,” for civil action suit

“captioned Onyinye Jideani vs. Hilton Worldwide Holdings Inc. (formerly

Hilton Hotel Corporation).”

PS' 5 Gf £0

TABLE OF AUTHORITIES CITED

CASES

PAGE NUMBER

A. Petitioner Onyinye Jideani's May 09, 2022 Unlawful

Discriminatory Practice claim civil action suit against the

Respondent Hilton Worldwide Holdings Inc., (formerly Hilton

Hotel Corporation) in the District of Columbia

Superior Court, case No. 2022 CA 2012 B under judge

Robert Rigsby......................................................... ..................

B. Petitioner Onyinye Jideani's November 08, 2022 Notice,

appealing the dismissal of the May 09, 2022 Unlawful

Discriminatory Practice claim civil action suit in the

District of Columbia Superior Court, at the

District Columbia Court of Appeals (DCCA), appeal case No. 22-CV-866...

pg. 11-17

pg. 13

C. The June 08, 2021 “interpleader” suit "case No. 2021 CA

001861 B under judge Robert R. Rigsby in D.C. Superior

Court civ. act. division," to dispute attorney lien with

regards to petitioner Onyinye Jideani's

November 14, 2019 automobile accident suit case No. 2019 007542 V,"

"and when judge Robert R. Rigsby subjected petitioner

Onyinye Jideani to bias and prejudicial misconduct"................................ pg. 11

STATUTES AND RULES

Federal Status*

A. 42 U.S Code § 1981: Equal Rights Under the Law

pg. 2,18

B- 42 U.S. Code / 1985:: Depriving Persons of Rights and Privileges

pg. 2,18

C. 28 U.S. Code 2072: Rules of Procedure and Evidence;

pg. 18,19

Power to Prescribe

D. 28 U.S. Code § 2106: Judiciary and Judicial Procedure: Determination....pg. 18,19

E- 28 U.S. Code § 453: Oaths of Justices and Judges

pg-11

28 U.S. Code § 144: Bias or Prejudice of a Judge...

■pg. 11

PS- b

TABLE OF AUTHORITIES CITED

The District of Columbia Statue:

G. uoae of tne District ot Coiumoia: District of Columbia Human Right Law:

DC Code §2-1401.01 - 2-1404.04: The Human Rights Act of

1977, Title 2, Chapter 14; Unit A, Part D: Public Accommodation,

Subchapter II........................... ..................................... ...................... pg.14-17

H. Code of the District of Columbia: District of Columbia Human Right Law:

DC Code §2-1401.01 - 2-1404.04: The Human Rights Act

of 1977, Title 2, Chapter 14; Subchapter III.

Procedure: DC Code §2-1403.16: Private Cause

of Action in any court of competent jurisdiction for damages and such other

pg. 14-17

remedies as may be appropriate....

!■ District of Columbia Code § 13-423:: Personal Jurisdiction Based Upon

pg.14-17

Conduct: Code of Judicial...............

Rule of Civil Procedure under the Federal and DC Superior Court:

A* Rule 41(b): Want of Prosecution............ . . ...... ........ ....................... pg- 2

OTHER

A. Black Law Dictionary: Want of Prosecution........................................

B. Hilton Worldwide Holdings Inc., 2021 Annual Report on

Form 10-K to the United States Security and Exchange Commission.

pg- 2

IN THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR WRIT OF CERTIORARI

Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.

OPINIONS BELOW

[ ] For cases from federal courts:

The opinion of the United States court of appeals appears at Appendix

the petition and is

[ ] reported at

; or,

[ ] has been designated for publication but is not yet reported; or,

[ ] is unpublished.

The opinion of the United States district court appears at Appendix

the petition and is

; or,

[ ] reported at

[ ] has been designated for publication but is not yet reported; or,

[ ] is unpublished.

[XI For cases from state courts:

The opinion of the highest state court to review the merits appears at

Appendix__ A_ to the petition and is

t ] reported at The District of Columbia Court of Appeals ; or,

[ ] has been designated for publication but is not yet reported; or,

[ ] is unpublished.

The opinion of t.hpThe District of Columbia Superior Court Civ ^

appears at Appendix _K

to the petition and is

[ ] reported at This District of Columbia Court of Appeals 0r,

[ ] has been designated for publication but is not yet reported; or,

[ ] is unpublished.

1.

to

to

JURISDICTION

[ ] For cases from federal courts:

The date on which the United States Court of Appeals decided my case

was

[ ] No petition for rehearing was timely filed in my case.

[ ] A timely petition for rehearing was denied by the United States Court of

, and a copy of the

Appeals on the following date:----------------order denying rehearing appears at Appendix

[ ] An extension of time to file the petition for a writ of certiorari was granted

(date)

(date) on

to and including______

in Application No.__ A

The jurisdiction of this Court is invoked under 28 U. S. C. § 1254(1).

|X] For cases from state courts:

The date on which the highest state court decided my case was March 21^ 2023

A copy of that decision appears at Appendix —A----Od A timely petition for rehearing was thereafter denied on the following date:

March 22, 2023

t and a copy of the order denying rehearing

appears at Appendix Q

[ ] An extension of time to file the petition for a writ of certiorari was granted

(date) in

(date) on

to and including____

Application No.__ A

The jurisdiction of this Court is invoked under 28 U. S. C. § 1257(a).

A.

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

Federal Status:

-42 U.S. Code § 1981: Equal Rights Under the Law

-42 U.S. Code 1985: Depriving Persons of Rights and Privileges

-28 U.S. Code § 2072: Rules of Procedure and Evidence; Power to Prescribe 28

-U.S. Code 2106: Judiciary and Judicial Procedure: Determination

-28 U.S. Code 453: Oaths of Justices and Judges

-28 U.S. Code 144: Bias or Prejudice of a Judge

The District of Columbia Statue:

-Code of the District of Columbia:

District of Columbia Human Right Law: DC Code §2-1401.01 - 2-1404.04:

The Human Rights Act of 1977, Title 2, Chapter 14;

Unit A, Part D: Public Accommodation, Subchapter If

-District of Columbia Human Right Law: DC Code §2-1401.01 - 2-1404.04:

The Human Rights Act of 1977, Title 2, Chapter 14;

Subchapter III. Procedure: DC Code §2-1403.16:

Private Cause of Action in any court of competent jurisdiction for damages

and such other remedies as may be appropriate

-District of Columbia Code § 13-423: Personal Jurisdiction Based Upon Conduct

-Code of Judicial Conduct: Code 2.2; Code 2.3; Code 2.5; Code 2.6; and Code

2.11

Rule of Civil Procedure under the Federal and DC Superior Court

-Rule 41(b): Want of Prosecution

Other Sources:

-Black’s Law Dictionary: Want of Prosecution Hilton Worldwide Holdings Inc.,

2021 Annual Report on Form 10-K to the United States Security and Exchange

Commission

STATEMENT OF THE CASE

d).

On May 09, 2022, petitioner Onyinye Jideani commenced a

substantially justified cognizable claim of Unlawful Discriminatory

Practice civil action suit against the respondent Hilton Worldwide

Holdings Inc. "(formerly Hilton Hotel Corporation),” for an incident

that occurred at one of its brand hotel in Washington DC on May 25,

2021, in the District of Columbia Superior Court Civil Action Division

"civil action case No. 2022 CA2012 B;n The District of Columbia

Superior Court civil action division inferior judge assigned to preside

over the suit was grab-bag judge "Robert R. Rigsby;” Additionally,

judge Rigsby was also the civil action inferior judge who presided

over another one of petitioner Onyinye Jideani's civil action suit in

2021 for “Interpleader” on a 2019 automobile-accident injury civil

action suit settlement dispute for lien amount between the petitioner

Onyinye Jideani and the rouge attorney she hired to represent her in

such 2019 personal injury matter “(case No. 2019 CA 001861 B in

the DC Superior Court civil action division),” and where judge

Rigsby subjected petitioner Onyinye Jideani to bias and prejudicial

misconduct; (The 2019 “initial” automobile-accident injury civil

action suit "case No. 2019 CA 007542 V" in D.C. Sup. Crt. civ. act.

div., was under inferior/grab-bag judge Heidi Pasichow who refused

to rule on such "attorney lien” dispute after granting the attorney’s

motion to withdraw as Onyinye Jideani’s attorney, thereby initiating

the 2021 Interpleader case);

(2).

Moreover, the District of Columbia Superior Court civil action

division branch clerks, unlawfully misclassified the May 09, 2022

Unlawful Discriminatory Practice suit “(case No. 2022 CA2012 B

and captioned Onyinye Jideani vs. Hilton Worldwide Holdings Inc.

(formerly Hilton Hotel Corporation)),” as one for a Declaratory

Judgment claim suit, as appose to an unlawful discriminatory

practice claim suit, “unlawfully denying its legal and jurisdictional

substantial merits, as a claim warranted on an existing District of

Columbia statute "on the District of Columbia Human Rights Law

(DC Code § 2-1402.31 and § 2-1403.16(a)),” and judicable in the

District of Columbia Superior Court (“as a municipal district court of

competent jurisdiction in the District of Columbia”);”

4-

STATEMENT OF THE CASE

(3).

Furthermore, during the May 09, 2022 civil action legal proceeding

in D.C. Superior Court civil action division, Judge Robert R. Rigsby

engaged in unlawful and unjudicial conduct that reflected adversely

on his honesty, impartiality, temperament, and fitness to serve as a

judge when he (aj violated procedural judicial enforcement of the

law “by abuse of process and with abusive tactics,” (bj failed to

recuse himself pursuant to a timely and sufficient affidavit for

prejudicial misconduct filed by petitioner Onyinye Jideani (filed in

tie D.C. Sup., Crt. court docket on 06/06/2022), (cj failed to

administer his judicial responsibilities which reflected adversely on

his ability and fitness to serve as a judge when he issued an

08/23/2022 order rescheduling the August 26, 2022 initial

conference hearing “(referred to as a status hearing)” for the sole

purposes of addressing motions filed in the court docket, however

he never ruled on any of the motions filed “particularly on petitioner

Onyinye Jideani’s 05/17/2022 motion(s) for a court order for the

civil action branch clerks to appropriately classify this case as

an unlawful discriminatory practice claim suit pursuant to DC Code

§2-1403.16: Private cause of action, “as appose to the

inappropriate classification of "Declaratory Judgment” as it was so

inaccurately misclassified by the DC Superior Court civil action

branch clerks in attempt to deny its “adjudicative and jurisdictional

fact” substantial merits,” and £d) unlawfully dismissed the

05/09/2022 civil action suit during the first and only hearing held

on October 21, 2022 “(initial conference hearing referred to as a

status hearing),” and in a retaliatory manner; (written dismissal

order was issued on 10/25/2022).

(4).

Moreover, during the May 09, 2022 civil action legal proceeding in

D.C. Superior Court, judge Robert R. Rigsby, engaged in unlawful

and unjudicial practice “violating procedural judicial enforcement of

the law through abuse of process and with abusive tactics,” and

unlawfully dismissed the suit without prejudice for Want of

Prosecution “in a retaliatory manner,” and during the first ever

hearing held on October 21,2022; “Want of Prosecution is defined

STATEMENT OF THE CASE

as failure of a litigant to pursue the case;” Therefore, “unlawfully and

delusively abridging on petitioner Onyinye Jideani's substantive

right to litigate her “adjudicative, jurisdictional, and material fact,”

cognizable claim of unlawful discriminatory practice against the

respondent Hilton Worldwide Holding Inc. (formerly Hilton Hotel

Corporation) during the May 09, 2022 suit in D.C. Superior Court

civ. act. div.;" Thereby subjecting petitioner Onyinye Jideani to

further continual legal Injury;

(5).

Petitioner Onyinye Jideani filed a Notice of Appeal on November 08,

2022, appealing District of Columbia civ. act div., judge Rigsby's

October 25, 2022 order dismissing the May 09, 2022 Unlawful

Discriminatory Practice claim suit “for Want of Prosecution,” at the

District of Columbia Court of Appeals (DCCA), “DCCA appeal case

No. 22-CV-866;”

And on the grounds that, “the District of Columbia Superior

Court civil action division's unconstitutional, unlawful, and unjudicial

actions, does not only abridge petitioner Onyinye Jideani’s

substantive rights “(to the full and equal benefit of all laws and

proceedings for the security of persons and property),” but

challenges the District of Columbia Human Rights Act of 1977, Title

2, Chapter 14,” in its intent to secure an end to discrimination, and

of which is one of several state and federal statute enacted to

combat discrimination, and distinguishable in its own variable rights

and purpose of implementation to give further force to the basic

rights guaranteed by the constitution.”

(6).

However, the District of Columbia Court of Appeals (DCCA), further

subjected petitioner Onyinye Jideani to continual injuries by

violating exiting laws guaranteed by the U.S. Constitution when it

breached its duty to protect and preserve the substantive right of

pro se litigant “petitioner Onyinye Jideani,” in granting the

respondent “Hilton Worldwide Holdings Inc.’s (formerly Hilton Hotel

Corporation) February 28, 2023 renewed Motion for Summary

STATEMENT OF THE CASE

Affirmance n u on the lower court's unlawful and unjudicial dismissal

of the civil action suit for Want of Prosecution," even though the

District of Columbia Court of Appeal was aware that petitioner

Onyinye Jideani "did" plead and pursued her civil action suit with

“procedural, sufficient, and timely” filings, in the lower court “(the

District of Columbia Superior Court civil action division)," and as

shown in the lower court “courts docket;” Want of Prosecution is

defined in the Black Law dictionary, as “failure of a litigant to pursue

the case.”

(7).

The District of Columbia Court of Appeals (DCCA), further subjected

petitioner Onyinye Jideani to continual injuries when it erred to

redress the lower courts failed cognizance and abuse of process

on petitioner Onyinye Jideani’s May 09, 2022 substantially

justified Unlawful Discriminatory Practice claim suit against the

respondent Hilton Worldwide Holdings Inc. (formerly Hiiton Hotel

Corporation), because petitioner Onyinye Jideani’s May 09,

2022 complaint commencing the civil action suit in the lower

court,

provided sufficient substantive “facts” of unlawful

discriminatory practice that respondent Hilton Worldwide Holdings

Inc, (formerly Hilton Hotel Corporation) subjected petitioner

Onyinye Jideani to at one of its brand hotel on March 25, 2021,

and that is plausible on its face, in violation of an exiting District

of Columbia Law “the District of Columbia Human Rights Act of

1977, Title 2, Chapter 14, Unit A “DC Code §2-1402.31: Public

Accommodation,” and pursuant to “DC Code §2-1403.16: Private

cause of action in a court of competent jurisdiction; —All of

petitioner Onyinye Jideani’s legal filings in this case, have been

supported with factual evidence and material facts, as laid forth

in court proceedings that have occurred in DC Court of Appeals

and in the lower court at DC Superior Court civil action division.

STATEMENT OF THE CASE

(8).

Petitioner Onyinye Jideani’s May 09, 2022 unlawful discriminatory

practice claim civil action suit against respondent Hilton Worldwide

Holdings Inc. (formerly Hilton Hotel Corporation) in the District of

Columbia Superior Court civil action division, “and appealed in the

District of Columbia Court of Appeals (DCCA) on November 08,

2022 'on the lower court’s October 25, 2022 dismissal order for

Want of Prosecution,is a substantially justified case on the merits

for adjudicative facts, jurisdictional fact, and material facts with

direct evidence, and constitutionally warranted by an existing law

on the District of Columbia Human Rights Act of 1977, Title 2,

Chapter 14, Unit A: Part D “DC Code §2-1402.31: Public

Accommodation," and pursuant to “DC Code §2-1403.16: Private

cause of action in a court of competent jurisdiction,” because:

—The factual substantive details of the discriminatory actions

that the respondent subjected petitioner Onyinye Jideani to on

March 25, 2021 “and that petitioner Onyinye Jideani precisely

narrated on her May 09, 2022 complaint commencing the civil action

suit in the lower court with direct evidence,” “of which is plausible

on it's face, is as follows:

i.

Petitioner Onyinye Jideani was refused hotel stay

accommodation at the Homewood Suites by Hilton hotel

located at 1475 Massachusetts Avenue NW Washington DC 20005

“(a Hilton Worldwide Holdings Inc., brand company),” by

termination of petitioner Onyinye Jideani’s hotel stay on May 25,

2021 “just a week short into her two weeks stay from May 17 31, 2021," at such hotel; And where petitioner Onyinye

Jideani was specifically informed by Homewood Suites by

Hilton hotel "(a Hilton Worldwide Holdings Inc., brand

company),” that due to petitioner Onyinye Jideani’s inquiry on

the unusual split charge method on her credit-card by the hotel,

Homewood Suites by Hilton hotel felt it necessary

. I5

STATEMENT OF THE CASE

Onyinye Jideani’s hotel stay charge, as confirmation that her

hotel-stay accommodation has been terminated. Such

upscale Homewood Suites by Hilton hotel “(a Hilton

Worldwide Holdings Inc., brand company),” was occupied by

mainly persons of white race at the time;

ii.

Homewood Suites by Hilton hotel located at 1475

Massachusetts Avenue NW Washington DC 20005 “(a Hilton

Worldwide Holdings Inc., brand company),” would not have

taken such unjustified, unlawful, aggressive, and unwarranted

action against a paying customer in what it considered as

Hilton Worldwide Holding Inc.’s "upscale and all-suites”

hospitality brand hotel, if it was not due to petitioner Onyinye

Jideani’s race and other relative protected class under DCHR

Act; And of which such Homewood Suites by Hilton hotel was

occupied by mainly persons of white race at the time;

Hi.

Homewood Suites by Hilton hotel “(a Hilton Worldwide

Holdings Inc., brand company),” had no legal justification “(or

even a warranted cause relative to a breach of the hotel’s

accommodation policy),” to terminate petitioner Onyinye

Jideani’s stay at such public accommodation on May 25,

2021, and therefore Homewood Suites by Hilton hotel “(a

Hilton Worldwide Holdings Inc., brand company)” subjected

petitioner Onyinye Jideani’s to discrimination on the basis of

Appellant’s race “as a black female minority in such public

accommodation, "(and othr relative protected class under

DCHR ACT of which such hotel perceive petitioner Onyinye

Jideani to be, in an inferiority manner)," in violation of the

District of Columbia Human Rights Act of 1977 (DCHR), Title 2,

Chapter 14. "Petitioner Onvinve Jideani inquiring about the

hotel's policy on credit-card billing, is not a legal justification

nor a breach of the hotel's accommodation policy;"

STATEMENT OF THE CASE

iv.

History has accounted for “under race discrimination,” of

simitar unlawful discriminatory practice against minority

people of different races and backgrounds in similar public

accommodation places consider as upscale, and for mainly

persons of white race, hence the enaction of the Human Right

Act of 1977 in the federal District of Columbia;

v.

At alf times mentioned herein and as laid forth in petitioner

Onyinye Jideani’s May 09, 2021 complaint, respondent

violated petitioner Onyinye Jideani’s “Human Rights” under

the District of Columbia Human Rights Act of 1977, Title 2,

Chapter 14, Unit A: Part D “DC Code § 2-1402.31for directly

denying petitioner Onyinye Jideani hotel accommodation at

the Homewood Suites by Hilton hotel “(a Hilton Worldwide

Holdings Inc., brand company),” “(and a place of public

accommodation as defined under the DCHR Act),” based on

petitioner Onyinye Jideani’s race “(and any other applicable

protected class in such provision);”

vi.

As a direct result of respondent’s unlawful actions on May 25,

2021, petitioner Onyinye Jideani’s Human Rights were

violated, therefore petitioner Onyinye Jideani is entitled to

relief under Title 2, Chapter 14, of the DC Human Right Act of

1977 “DC Code § 2-1403.16(a)," and any other statute or

federal provision of law enacted to combat such unlawful

discriminatory practice; Such unlawful discriminatory practice

and humiliating injury that the respondent subjected petitioner

Onyinye Jideani to on May 25, 2021 violated state and federal

statutes, violated petitioner Onyinye Jideani's fundamental

and human right, and caused petitioner Onyinye Jideani great

inconvenience, expense, and emotional distress; And

therefore in addition to the relief set-forth under the DC

Human Right law, petitioner Onyinye Jideani is also seeking

relief under tort law; Hence a total judgement against the

respondent Hilton Worldwide Holding’s Inc. (formerly Hilton

Hotel Corporation) “(for relief sought and believed to be)” in

the amount of "Fifteen Million Dollars ($15,000,000.00)” in

compensatory damages and/or an amount to be determined

at trial, plus costs of suit, pre- and post- judgment interest,

and other and further penalties, civil penalties, and relief as

this court deems just and proper.

REASONS FOR GRANTING THE PETITION

The United States Supreme Court should grant petitioner Onyinye

Jideani’s Writs of Certiorari, because the District of Columbia Court of

Appeals (DCCA), has entered a decision that has so far departed from

the accepted and usual course of judicial proceedings, and or

sanctioned such a departure by the lower court "the District of Columbia

Superior Court Civil Action Division," as to call for an exercise of this

Court’s supervisory power, as:

(1.) The District of Columbia Court of Appeals (DCCA), subjected petitioner

Onyinye Jideani to continual injury, and further abridged on her substantive

rights when it erred to redress the District of Columbia Superior Court’s

failed cognizance and abuse of process, on petitioner Onyinye Jideani’s

May 09, 2022 substantially justified "Unlawful Discriminatory Practice"

claim suit against the respondent Hilton Worldwide Holdings Inc. (formerly

Hilton Hotel Corporation), thereby deprieving pro se litigant Onyinye

Jideani the full and equal benefit of all laws and proceedings for the

protection of persons and property;

(2.) The District of Columbia Court of Appeal's erroneous act, sanctioning

the the District of Columbia Superior Court's immoral and unlawful violation

of the law “and that of petitioner Onyinye Jideani’s legal right to the full

and equal benefit of all laws and proceedings,” by granting the

respondent's renewed motion for summary affirmance on the lower court's

unlawful and unjudicial dismissal of suit for Want of Prosecution, is an

unconstitutional defect disrupting the status quo and obstructing the

administration of justice; And a failure of the judiciary system in enforcing

the law, "which has deemed the District of Columbia Court of Appeal and

the District of Columbia Superior Court fraudulent and incompetent;

(3.) The District of Columbia Court of Appeals (DCCA), breached its duty

to redress the defect of the lower court "and to protect and preserve the

substantive right of pro se litigant “petitioner Onyinye Jideani,” when

granting the respondent “Hilton Worldwide Holdings Inc.’s (formerly Hilton

Hotel Corporation) Renewed Motion for Summary Affirmance” “and on the

lower court's unlawful and unjudicial dismissal of petitioner Onyinye

Jideani's May 09, 2022 civil action suit for Want of Prosecution during the

first and only hearing held on October 21, 2022;"

5-

And where the District of Columbia Court of Appeals, had substantial

knwledge and material facts that petitioner Onyinye Jideani "did" plead

and pursued her civil action suit with "procedural, sufficient, and timely"

filings, in the lower court "(the District of Columbia Superior Court civil

action division)," and as shown in the courts docket for the May 09, 2022

legal proceedings; And therefore the District of Columbia Superior Court

erred and engaged in abuse of process when dismissing the suit for Want

of Prosecution on an October 25, 2022 order;

WHEREFORE, pursuant to 28 U.S. Code 2106, the Supreme Court

Should certify and affirm all necessary remedial status to redress the

defect, injury, and injustice caused to the petitioner Onyinye Jideani,

"to preserve the status quo, protect the substantive rights of pro se

litigants, and uphold the full capacity of the administration of justice.

CONCLUSION

The petition for a writ of certiorari should be granted.

Respectfully submitted,

Da,

TV*

Date: Juj1&

J'/"dean ij 'fieb'-fifiner in pro

/3, $£>0-3